STATEMENT

We are committed to protecting your privacy and confidentiality and understand that your privacy is important. We are committed to the principles outlined in the Privacy Act 1988. Our privacy policy tells you about how we collect, hold, use and disclose your personal information.

SCOPE

Who does the Policy and Procedure apply to? This document sets out how we protect your privacy and manage your personal information. It applies to all people who deal with us, other than our employees.

DEFINITIONS

We: Means Give a Care Pty Ltd
Consent: Means Permission for something to happen or agreement to do something. Your consent can be written or verbal (eg, when you give us your permission over the phone or in a face to face conversation). Your consent will be implied where we can reasonably form a conclusion that you have given consent by taking action or deciding not to take action.
Person we support: Means a person who we are giving assistance to or has previously received services from us or has made inquiries to us about receiving services from us.
Personal Information: Means information we collect about you which forms part of our database
Sensitive Information: Is a category of personal information and includes your health or medical information.

1.1 Collection of your Personal Information

The amount and type of personal information we collect from you will depend on the type of activity we are required to do for you.

Personal information would include information on the individual’s identity (that is name, address, country of birth, gender, date of birth, telephone number, passport details, billing information and medicare number.

If you are a person we support or are connected to a person we support (eg, family member, carer, advocate or nominated representative), the personal information that we hold about you will include similar items as well.

If you are a job applicant, the personal information we hold about you may include (name, address, telephone number, gender, country of birth, previous employment details, email address, tax file number, qualifications, working with children checks, police checks.

1.2 Collection of Sensitive Information

We understand that protecting your privacy in relation to health and sensitive information is particularly important.

To provide our services or to respond to inquiries about our services, we may be required to collect and hold your sensitive information including health and medical information and information relating to your disability and support requirements.

We will limit the collection of sensitive information to the minimum amount required in the circumstances.

You can refuse to provide this information at any time, however in doing so, this may limit our capacity to provide you with a person centred care plan, that is individually tailored to you.

1.3 Collection of Personal Information

Your personal information is collected from you in a number of ways:
• Over the phone when you contact us or via email or in person
• When you fill in our application forms
• When you inquire about our services or supports or receive our services and support
• When you donate to us or participate in any of our fundraising activities
• Through our direct marketing activities
• Through our contracted service providers

Where possible, we will collect your personal information directly from you or your nominated representatives. However, there may be circumstances in which we need to collect your information from other people or organisations.

If we collect personal information about you from a third party and it is unclear that you have consented to the disclosure of your personal information to us, we will take reasonable steps to contact you and ensure that you are aware of the circumstances surrounding the collection and purposes for which we have collected your personal information.

If you have provided us with information about another person, then you need to tell that other person that you have done so, that they have a right to access their information and that they can refer to the Privacy Policy for information on how Give a Care will handle their personal information.

It is also OK to change your mind re your consent to Give a Care to collect and share your information – but you need to let us know of your change in your wishes.

Similarly, you may use a pseudonym and or choose to remain anonymous when consenting to share your information. However this may limit our ability to meet your individual needs.

1.4 Use of your Personal Information

Your information is used to enable us to operate our business especially as it relates to you. This may include:
• For the provision of services
• To verifying your identity
• Use in marketing and promotions
• Processing your membership
• Send you information about our services and supports
• Investigating any complaints about or made by you
• As required or permitted by any law (including the Privacy Act)

If you are a person we support or are connected to a person we support (eg, chosen family member, advocate or nominated representative), we may use your information to:
• Provide you with information about our services and supports
• Administer our services and supports
• Process payments
• Answer your inquiries and deliver customer service to you
• Conduct quality assurance activities
• Carry out internal functions including administration, training, accounting, audit and information technology
• Resolve complaints
• Comply with laws and regulations and to report to funding and government agencies
• Send you information about our organisation, services and

1.5 Who Does Give a Care Disclose Information to

In order to operate an efficient and sustainable organisation and to enable us to carry out our activities and provide our services and supports, we may be required to disclose your personal information
to third parties. This may include disclosure in the following circumstances:
• The use or sharing of information is legally required or authorised by an Australian law, or court or tribunal order
• Give a care believes that the collection and disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of an individual
• Related and affiliated companies and organisations including joint venture partners and industry affiliate organisations.
• People engaged by us or acting on our behalf in relation to our business, such as our service providers/suppliers. Suppliers are required to handle your personal information in accordance with this Privacy Policy.
• Government and regulatory bodies, including the National Disability Insurance Agency, Medicare, the Department of Social Services, the Department of Health & Human Services, and the Australian Taxation Office.
• People acting on your behalf including your nominated representatives, legal guardians, executors, trustees and legal representatives.
• Lawyers, auditors, banks and other advisors appointed by us or acting on our behalf.
• Where disclosure is required by law, including where required to the police, or to the Disability Services Commissioner, or to comply with compulsory notices from courts of law, tribunals or government agencies.

We take reasonable steps to make sure that these organisations will protect the privacy of your personal information, in accordance with this Privacy Policy.

1.5.1 Cross border disclosure of information

Give a Care will ensure we take reasonable steps before disclosing information to ensure that the recipient treats the personal information with the similar standard of care required by the Information Privacy Act. Our technology infrastructure may make use of cloud infrastructure or servers located outside Australia. We do take all reasonable steps to secure your private and sensitive information against unauthorised access. Apart from this, we do not typically transfer personal information offshore. By providing your personal information to us or using our services and supports, you are taken to have consented to this transfer.

1.5.2 How do we store personal information and for how long?

We take all reasonable steps to ensure that your personal information is securely stored and protected. These steps include password protection for accessing our electronic IT systems, securing paper files in locked cabinets and physical access restrictions to buildings where information is held. In addition, access to your personal information is restricted to those properly authorised to have access.

Unfortunately, there are inherent risks in the management of personal information and we cannot and do not guarantee that unauthorised access to your personal information will not occur. We keep your personal information for as long as it is needed for the purposes for which it was collected and to comply with legal requirements. When personal information we hold is no longer needed for any purpose, including legal purposes, and subject to our legal obligations (for example, under the Public Records Act), we will take reasonable steps to destroy or alter that information so that it no longer identifies you.

1.6 Assessing and Correcting your Personal Information

1.6.1 How do I keep my personal information up to date?

We depend largely on you to provide us with accurate personal information. If changes to your information are required, please let us know by contacting us.

1.6.2 Can I access my personal information?

Individuals can access their information at any time in a suitable format without charge.

Simply contact us (our contact details are listed below) to make your request. For security reasons, we may ask you to put your request in writing. However, there may be some circumstances when this is not possible, including where:
• We no longer hold or use the information
• providing access would have an unreasonable impact on the privacy of others
• The request is frivolous or vexatious
• Providing access would be unlawful

If we do not provide you with access to all of your personal information, we will tell you the reason why we have not done so.

1.7 Your Privacy Online

1.7.1 Online data collection and use
When you access a Give a Care website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited.

This information is used by Give a Care to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.

1.7.2 How we handle email and ‘contact us’ messages
We may keep the content of any email, or “Contact us” or other electronic message or form, that we receive. The message content may be monitored by our service providers or staff for purposes including trouble shooting, compliance, auditing and maintenance, or where email abuse is suspected. Personal information will be handled in accordance with this Privacy Policy.

1.7.3 Additions to this Policy
If we decide to change this Privacy policy, we will post changes on our webpage www.giveacare.com.au Please refer back to our Privacy Policy to review any changes.

You can also seek further information and advice from the Office of the Australian
Information Commissioner by calling 1300 363 992.

REFERENCES
• National Standards for Disability Services
• Department Human Services Service Standards
• ISO Standard 9001/2008
• What the My Aged Care Regional Assessment Service means for Commonwealth
• Home Support Program Providers (2015):
https://agedcare.health.gov.au/sites/g/files/net1426/f/documents/04_2015/what_the_ras_means_for_chsp_providers_fact_sheet_-_1_april_2015_accessible_version.pdf
Practices and Processes Guide, (2015):
https://www.aacqa.gov.au/forproviders/home-care/practices-and-processes-guide
• Home Care Packages program, (2015):
https://agedcare.health.gov.au/sites/g/files/net1426/f/documents/12_2015/home_care_packages_programme_operational_manual-december-2015.pdf
• Consumer Directed Care (Aug 2016):
https://www.myagedcare.gov.au/aged-careservices/home-care-packages/consumer-directed-care-cdc
• Find and Connect (Feb 2016):
https://www.findandconnect.gov.au/guide/vic/E000605

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